Privacy & Cookie Policy

February 2024

As a visitor to this website, City of London Investment Group plc is committed to protecting your privacy and maintaining the confidentiality and security of your information. This Privacy Policy will help you understand how we safeguard the personal information we collect and how we use it to service you and your account.

City of London Investment Group plc (“CLIG”) has adopted this Notice for all of its subsidiaries and related entities (collectively, “CLIG”, “we”, “our” or “us”) pursuant to articles 13 and 14 of the EU Regulation 2016/679, the United Kingdom General Data Protection Regulation (GDPR) as defined in section 3(10) of the Data Protection Act 2018 (DPA 2018), supplemented by section 205(4), the California Consumer Privacy Act of 2018 and other applicable data protection and privacy laws (hereinafter the “Regulation“) concerning the processing of personal data of users and registered users of its website www.clig.co.uk and www.clig.com (hereinafter referred to as the “Website”).

1. Who is the controller of my data?
   The controller of your personal data is City of London Investment Group plc, with registered office at 77 Gracechurch Street, London EC3V 0AS, United Kingdom registered in England and Wales under no. 2685257.
2. If I am a visitor of the Website, what types of data are processed and for what purposes?
   If you are a visitor of the Website (registered or unregistered), the following types of personal data will be processed and for the following purpose:
   Navigation data: the information systems and software procedures relied upon to operate this Website acquire personal data as part of their standard functioning; the transmission of such data is an inherent feature of Internet communication protocols. Such information is not collected to relate it to identified data subjects, however it might allow user identification per se after being processed and matched with data held by third parties. This data category includes IP addresses, and/or the domain names of the computers used by any user connecting with this Website, the URI (Uniform Resource Identifier) addresses of the requested resources, the time of such requests, the method used for submitting a given request to the server, returned file size, a numerical code relating to server response status (successfully performed, error, etc.), and other parameters related to the user’s operating system and computer environment. Except as provided in the following paragraph 8 in relation to the use of cookies on the Website, this data is only used to extract anonymous statistical information on Website use as well as to check functionality and is erased immediately after being processed. However, such data might be used to establish liability in case computer crimes are committed against the Website. Navigation data processing is necessary for our legitimate interests to guarantee the Website security.
   Data provided voluntarily by the User: spontaneous e-mail transmitted to us: please note that sending e-mail messages to the addresses mentioned on the Website, which is done based on a freely chosen, explicit, and voluntary option, entails acquisition of the sender’s personal data, which is necessary to reply to any request on services or products. Providing such personal data is optional but failure to provide them would imply the impossibility to obtain the requested information. CLIG does not and will not sell your personal information.
3. If I am a registered user of the Website, what are the purposes of the processing?
   If you are a registered user of the Website, your personal data will also be processed to allow you to access the services of the restricted area of the Website, as well as to implement pre-contractual measures adopted at your request, such as in case you should ask for information in relation to our products or services and/or in relation to the Website, and to provide any assistance requested by you.
4. Is the provision of the data mandatory or optional?
   Providing your personal data is optional but failure to provide such would imply the impossibility to register to the Website and be provided with the requested services.
5. Do you process my data also for other marketing purposes?
   Should you provide consent to subscribe via our e-alert service, we will process your data for marketing purposes (e.g. direct sale, sending advertising material, market research and commercial communication), and for sending you e-mail promotional communications (Newsletters) related to products and services. The e-alert service (hereinafter the “E-Alert Service”) is a notification service available through our website that allows users to receive via e-mail free newsletters and other marketing material about products, services and events related to CLIG.To register for E-Alert Service, your name and e-mail address along with your consent to the processing of such data for marketing purposes shall be provided. Following the registration, you will receive an email asking you to confirm your consent. Should you decide not to give your consent, you will be removed from the E-Alert Service. You may freely withdraw your consent at any time by contacting us via mail to the contact details indicated in paragraph 13 below. For promotional communication sent by e-mail (Newsletters) you may withdraw your consent to the processing of your e-mail address for marketing purposes by clicking on the opt-out link contained in each promotional e-mail.It should be noted that the E-Alert Service is performed by Investis Ltd., a company registered in England and Wales whose registered address is at 24 Fashion Street, London E1 6PX., which acts as Data Processor, on behalf of CLIG.Investis Ltd processes the registered users’ personal data (name, surname and e-mail address) both directly and through its two subsidiaries acting as “sub-controllers”.For further details concerning the two subsidiaries mentioned above, please refer to paragraph 7 below.
6. How is my data processed and for how long will my data be stored and processed?
   Your personal data will be processed both by electronic and non-electronic means, for the intended purpose in a manner that ensures appropriate security and confidentiality of the personal data.If you have contacted us via e-mail to obtain pre-contractual information on our products and/or services, your personal data will be retained and stored until the requested information is processed, unless the further storage of data is required to comply with legal obligations.When you consent to the processing of your personal data for marketing purposes, your personal data will be retained until you have withdrawn consent to the processing of your data for marketing purposes for all or some contact methods.Personal data of registered users will be retained and stored for as long as your account is active or for the further period necessary to comply with legal obligations.
7. Will my data be transferred outside the European Economic Area?
   Solely for the E-Alert Service indicated in paragraph 5 above, your personal data (full name and e-mail address) will be transmitted outside the European Economic Area. The E-Alert Service is performed by Investis Ltd. on CLIG’s behalf. Therefore, Investis Ltd., a UK based company, will have access to the users’ personal data necessary for the performance of the service. Investis Ltd. will transmit the user’s personal data collected through the E-Alert Service to its two subsidiaries based, respectively in the United States and India, namely (i) Investis Inc., with registered office at 240 W 37th Street, Floor 7, New York, NY 10018 – United States, providing services of customer support for issues with the E-Alert Service and (ii) Investis Corporate Communications PVT Ltd., with registered office in Royal House part E, Atlantis Lane, Sarabhai Campus, Vadi Wadi, Vadodara 390 007, Gujarat, – India, providing services of customer support for issues with the E-Alert Service.Please consider that India is a third country that does not offer adequate protection under the Regulation, in relation to which there is no decision on the adequacy by the European Commission. To protect your personal data, Investis Ltd. entered the standard data protection clauses adopted by the European Commission with Decision 2010/87/ EU, in accordance with Article 46.2 of the Regulation. You have therefore the right to obtain a copy of these standard clauses and to obtain information about the recipients or categories of recipients to whom the personal data have been or will be communicated, sending a request to CLIG according to paragraph 13 below. Your data will also be available to subsidiaries of CLIG.
8. Does your Website use cookies?
   Yes, it does. Please read our Cookie Policy described below.
9. Who may have access to the data?
   The following subjects may have access to your personal data as data processor: our employees and collaborators which are responsible for maintaining and operating the Website, assisting the clients and prospective clients, and/or carrying out the marketing activities, as well as external service providers which, acting as external data processors, provide services for the management of the IT systems and communications network, advisors, auditors, companies providing marketing services, and other support and management services providers.
10. Will my data be communicated to third parties or disseminated?
    CLIG does not disclose client information to anyone, except as permitted by law and as is deemed necessary by CLIG to provide our services to your account.
11. What are my rights?
    You will be able to exercise the rights set forth in the Regulation, including the following rights: the right to request the access to personal data (i.e. the right to obtain from us confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, to obtain access to the personal data, by obtaining a copy, and the information set forth in the Regulation) and the rectification (i.e. the right to obtain the rectification of inaccurate personal data concerning you or the integration of incomplete data) or the erasure (i.e. the right to obtain the erasure of personal data concerning you, where one of the grounds listed in the Regulation applies) or the restriction of processing concerning you (i.e. the right to obtain that the data are marked in a way to limit the processing in the future), as well as the right to data portability (i.e. the right to receive from us the personal data concerning you, in a structured, commonly used and machine-readable format and the right to transmit those data to another controller without hindrance). You have the right to withdraw your consent at any time. The consent withdrawal will not affect the validity of the processing based on your consent before the withdrawal. You also have the right to file a complaint with the Data Protection Authority (https://ico.org.uk) or with the Data Protection Authority of the EU Member State where you have your residence or work, or with your resident state authority.
12. Do I have the right to object to the processing under the Regulation?
    Yes, you have the right to object, on grounds relating to your situation, at any time to the processing of personal data concerning you pursuant to the Regulation, including profiling based on these provisions. Should your personal data be processed for direct marketing purposes, you have the right to object to the processing of personal data concerning you at any time, including the profiling to the extent that it is linked to such direct marketing.
13. How can I exercise my rights?
    The above-mentioned rights can be exercised by mail sent to City of London Investment Group plc at the address “77 Gracechurch Street, London EC3V 0AS, United Kingdom” or via email.

Cookie Policy

February 2024

This Cookies Policy explains what Cookies are, how We use them, and how to manage Your cookies. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about You may be linked to the information stored in and obtained from Cookies. For further information on how We use, store and keep your personal data secure, see our Privacy Policy.

We do not store sensitive personally identifiable information, such as mailing addresses, account passwords, etc. in the cookies We use.

Definitions

For the purposes of this Cookies Policy:

• Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Cookies Policy) refers to City of London Investment Management Company Limited, 77 Gracechurch Street, London EC3V 0AS, United Kingdom.
• You means the individual accessing or using the Website, or a company, or any legal entity on behalf of which such individual is accessing or using the Website, as applicable.
• Cookies means small files that are placed on Your computer, mobile device or any other device by a website, containing details of your browsing history on that website among its many uses.
• Website refers to City of London Investment Management Company Limited, accessible from www.citlon.com.

The Use of the Cookies

Type of Cookies We Use

Cookies can be “Persistent” or “Session” Cookies. Persistent Cookies remain on your personal computer or mobile device when You go offline, while Session Cookies are deleted as soon as You close your web browser.

We use both Cookies for the purposes set out below:

Necessary / Essential Cookies

These Cookies are essential to provide You with services available through the Website and to enable You to use some of its features. They help to authenticate users and prevent fraudulent use of user accounts.

Functionality Cookies

These Cookies allow us to remember choices You make when You use the Website, such as remembering your login details or language preference. The purpose of these Cookies is to provide You with a more personal experience and to avoid You having to re-enter your preferences every time You use the Website.

The following Cookies are currently used on the Website:

Targeting & Advertising

We partner with a non-affiliated third party service provider, Google, that performs services on our behalf, such as compiling web statistics. This third party service provider only uses your information to perform the services for which they were hired or as otherwise permitted under applicable law. This third party service provider has their own privacy policies and may be different from ours.

Your Choices Regarding Cookies

If You prefer to avoid the use of Cookies on the City of London Investment Management Company Limited website, first You must disable the use of Cookies in your browser and then delete the Cookies saved in your browser associated with this www.citlon.com. You may use this option for preventing the use of Cookies at any time.  

Follow the instructions given by the developer of your internet browser to find out how to control, disable or erase some or all the cookies/technical and analytics):

• Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/view-cookies-in-microsoft-edge-a7d95376-f2cd-8e4a-25dc-1de753474879
• Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Firefox: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
• Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Opera: http://help.opera.com/Windows/10.00/en/cookies.html

If You do not accept Our Cookies, You may experience some inconvenience in your use of the Website and some features may not function properly.

Contact Us

If you have any questions about this Cookies Policy, you can email us at info@citlon.com.

For further information on cookies and your specific rights please visit the web-site of the UK Data Protection Authority (Information Commissioner’s Office (ICO)) https://ico.org.uk or your resident state authority.